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Home My Public Portal AboutExhibit MSD 51 MSD 2nd Discovery Request to BJH 080511 (B LaConte)Exhibit MSD 51 BEFORE THE RATE COMMISSION OF THE METROPOLITAN ST. LOUIS SEWER DISTRICT AUGUST 5, 2011 SECOND DISCOVERY REQUEST OF THE METROPOLITAN ST. LOUIS SEWER DISTRICT ISSUE: WITNESS: SPONSORING PARTY: DATE PREPARED: WASTEWATER RATE CHANGE PROPOSAL BILLIE S. LaCONTE DRAZEN CONSULTING GROUP, INC. METROPOLITAN ST. LOUIS SEWER DISTRICT AUGUST 5, 2011 Metropolitan St. Louis Sewer District 2350 Market Street St. Louis, Missouri 63103 1 EXHIBIT 51 BEFORE THE RATE COMMISSION OF THE METROPOLITAN ST. LOUIS SEWER DISTRICT For Consideration of a Wastewater Rate Change Proposal by the Rate Commission of the Metropolitan St. Louis Sewer District AUGUST 5, 2011 SECOND DISCOVERY REQUEST OF THE METROPOLITAN ST. LOUIS SEWER DISTRICT Pursuant to §§ 7.280 and 7.290 of the Charter Plan of the Metropolitan St. Louis Sewer District (the "Charter Plan"), Operational Rule 3(2) and Procedural Schedule §§ 1, 14, 15 and 17 of the Rate Commission of the Metropolitan St. Louis Sewer District ("Rate Commission"), the Metropolitan St. Louis Sewer District ("District") requests additional information and answers from Billie S. LaConte, Drazen Consulting Group, Inc. ("Drazen") regarding the Rate Change Proposal dated May 10, 2011 (the "Rate Change Proposal"). Drazen is requested to amend or supplement the responses to this Discovery Request, if Drazen obtains information upon the basis of which (a) Drazen knows that a response was incorrect when made, or (b) the Drazen knows that the response, though correct when made, is no longer correct. The following Discovery Request is deemed continuing so as to require Drazen to serve timely supplemental answers if Drazen obtains further information pertinent thereto between the time the answers are served and the time of the Prehearing Conference. 2 EXHIBIT 51 AUGUST 5, 2011 SECOND DISCOVERY REQUEST OF THE METROPOLITAN ST. LOUIS SEWER DISTRICT 1. On page 7, lines 4 through 6, of Ms. LaConte's rebuttal testimony, she references Brian Hoelscher's statement "due to economic conditions, the District will be receiving bids for capital work that in some cases were 40% below traditional cost." On page 7, lines 7 and 8, Ms. LaConte further references Mr. Hoelscher's statement "current economic conditions were not assumed to be in place during the current proposed rate study period." Based on these statements, on page 7, lines 8 and 9, Ms. LaConte concludes the cost of District's CIRP may be overstated "which could lead to higher - than -necessary rate increases." Is Ms. LaConte's conclusion based on current economic conditions remaining unchanged through FY16? Are there any economic factors outside the District's control which could change prior to FY16? If so, how, in Ms. LaConte's opinion would these factors impact the cost of the District's CIRP? Susan Myers, General Counsel METROPOLITAN ST. LOUIS SEWER DISTRICT 2350 Market Street St. Louis, Missouri 63103 smyers@stlmsd.com Tel: (314) 768-6200 Fax: (314) 768-6372 3 EXHIBIT 51 CERTIFICATE OF SERVICE The undersigned hereby certifies that on the 5th day of August, 2011: An electronic copy of the foregoing instrument was emailed to the Secretary of the Rate Commission c/o jfenton@stlmsd.com SECRETARY OF RATE COMMISSION: Ms. Nancy Bowser Secretary of Rate Commission Metropolitan St. Louis Sewer District 2350 Market Street St. Louis, MO 63103-2555 robowser@swbell.net At the request of Rate Commission Counsel, one paper original and associated Exhibits are held at the Rate Commission office for Commissioner review. An electronic copy of the foregoing instrument and Exhibits were emailed to: RATE COMMISSION LEGAL COUNSEL: RATE COMMISSION CONSULTANT: COVIDIEN: Lisa O. Stump, Esq. Lashly & Baer, P.C. 714 Locust Street St. Louis, MO 63101 lostump@lashlybaer.com Mr. William Stannard President Raftelis Financial Consultants, Inc. 3013 Main Street Kansas City, MO 64108 wstannard@raftelis.com Mr. Randy Meyer Utility Manager Covidien 3600 North 2nd Street St. Louis, MO 63147 Randy.Meyer@covidien a,com 4 EXHIBIT 51 ROBERT A. MUELLER: Mr. Robert A. Mueller 16 Ladue Crest Lane St. Louis, MO 63124 ramreco@sbcglobal.net BARNES JEWISH HOSPITAL: Ms. Lisa Langeneckert Sandberg, Phoenix and VonGontard P.C. One City Centre, Suite 1500 St. Louis, MO 63101 llangeneckert@sandbergphoenix.com MISSOURI INDUSTRIAL ENERGY John Kindschuh, Esq. CONSUMERS: Bryan Cave, LLP 211 N. Broadway, Suite 3600 St. Louis, MO 63102 John.kindschuh(a,bryancave. com Diana M. Vuylesteke, Esq. Bryan Cave, LLP 211 N. Broadway, Suite 3600 St. Louis, MO 63102 dmvuylesteke@bryancave. com Susan Myers, General Couns METROPOLITAN ST. LOUIS SEWER DISTRICT 2350 Market Street St. Louis, Missouri 63103 smyers@stlmsd.corn Tel: (314) 768-6200 Fax: (314) 768-6372 5